Cullen v. Pinholster

Case Date: 11/09/2010
Docket No: none

Facts of the Case 

A California state court convicted Scott Lynn Pinholster of double murder and sentenced him to death. After exhausting his state court remedies, he petitioned for habeas corpus relief in a California federal district court, arguing that he was denied effective assistance of counsel at both the guilt and sentencing phases of his trial. The district court upheld Pinholster's conviction but granted habeas relief on his death sentence. The district court affirmed the conviction but reversed the grant of habeas relief on the death sentence.

The U.S. Court of Appeals for the Ninth Circuit reversed the lower court order, holding that the denial of habeas relief during the guilt phase was appropriate, but not during the penalty phase. The court noted that Strickland v. Washington requires trial counsel to investigate mitigating evidence at the penalty phase. Here, the court reasoned that Pinholster's counsel failed meet to meet his obligations.

Read the Briefs for this Case
  • Brief Amicus Curiae of the Criminal Justice Legal Foundation In Support of Petitioner
  • Brief of Disability Rights Legal Center as Amicuscuriaein Support of the Respondent
  • Question 

    Can a federal court overturn a state criminal conviction on the basis of facts the defendant could have alleged, but did not, in state court?

    Argument Cullen v. Pinholster - Oral ArgumentFull Transcript Text  Download MP3Cullen v. Pinholster - Opinion AnnouncementFull Transcript Text  Download MP3 Conclusion  Decision: 5 votes for Cullen, 4 vote(s) against Legal provision: ADEPA

    No. The Supreme Court reversed the lower court order in an opinion by Justice Clarence Thomas. Limiting "review to the state-court record is consistent with our precedents," Thomas wrote for the 5-4 majority. Justice Stephen Breyer filed a partial dissent in which he contended that "I do not join Part III, for I would send this case back to the Court of Appeals so that it can apply the legal standards that Part II announces to the complex facts of this case." Justice Sonia Sotomayor, joined by Justices Ruth Bader Ginsburg and Elena Kagan, dissented in full. "Some habeas petitioners are unable to develop the factual basis of their claims in state court through no fault of their own," Sotomayor argued.